Pennsylvania opioid treatment agreements, documented from Act 112 outward

Status: Pennsylvania evidence build reviewed through October 4, 2026. This library separates the statutory agreement mandate, testing rules, state implementation materials, PDMP duties, professional enforcement, continuity safeguards, and future practice-specific evidence.

Current legal baseline

Act 112 of 2019 added 35 Pa.C.S. Chapter 52B and requires prescribers to establish an opioid treatment agreement before the first prescription in a new single course of chronic-pain treatment with a controlled substance containing an opioid.

State requirement Pennsylvania rule
Agreement timing Before the first prescription in the covered chronic-pain treatment course.
Treatment goals Required agreement subject.
Testing consent Consent to targeted testing when medically necessary.
Medication adherence Take medication as prescribed; do not share it.
Other controlled substances Must be disclosed.
Change/discontinuation criteria Must be included.
Unused-opioid disposal Must be addressed.
Medical-record retention Agreement is maintained in the patient’s medical record.

Pennsylvania state-level records

Testing framework

Pennsylvania requires baseline urine testing before the initial chronic-pain opioid prescription and risk-based follow-up testing. Patients treated for addiction or considered moderate or high risk must be tested at least annually or more often as necessary. The law and temporary regulations include documented exceptions and allow medically necessary alternative testing when urine cannot be produced.

The state publishes its own model and checklist

The Department of Health currently provides a Sample Treatment Agreement, Act 112 checklist, prescriber considerations, FAQs, and patient-education materials. Those resources are important because the Department expressly states that Act 112 does not require one-pharmacy-only policies, does not require targeted blood tests, and should be implemented with clinical judgment and non-stigmatizing language.

PDMP is a separate legal layer

Pennsylvania generally requires a PDMP query the first time a controlled substance is prescribed, each time an opioid or benzodiazepine is prescribed, and when misuse or diversion is suspected. Those duties remain even when a patient has already signed a treatment agreement.

Continuity and tapering safeguards

The temporary regulations allow a prescriber to terminate an agreement when it is no longer necessary but require documentation, patient notice, and continuity-of-care efforts when needed. The Department’s Patient Advocacy Program separately warns about the risks of abrupt cutoff and rapid tapering in physically dependent patients.

Professional enforcement

Act 112 violations are subject to sanctions under the prescriber’s professional practice act and by the appropriate licensing board. The agreement mandate is therefore not merely advisory.

Current regulation status

Act 112 took effect November 27, 2019. The Department adopted 28 Pa. Code Chapter 26 effective March 7, 2020. As of October 4, 2026, the Pennsylvania Code and Department of Health continue to identify Chapter 26 as the Act 112 temporary regulations, while the statutory mandate remains in force.

Practice-agreement evidence gap

Pennsylvania’s official state record is unusually complete. This library therefore does not pad the state file with generic national contracts or weakly sourced clinic forms. Current Pennsylvania practice agreements will be added when their provenance and current use can be verified.

Formal change route

The core agreement mandate is written directly into Chapter 52B. Removing it requires legislative amendment through the Pennsylvania General Assembly. Current health-policy gatekeepers are House Health Committee Chair Dan Frankel and Senate Health and Human Services Committee Chair Michele Brooks. The Department of Health, led by Secretary Debra L. Bogen, administers implementation but cannot repeal the statute administratively.

Submit a missing Pennsylvania agreement

Submit a Pennsylvania Contract for Care

Primary Pennsylvania authorities

Reviewed: October 4, 2026.

Evidence boundary: Pennsylvania’s agreement mandate is statutory and enforceable. Department guidance, temporary regulations, PDMP duties, and clinic-added terms remain distinct evidence layers.